cruelty-free: some comments

Before putting up my big long list of cruelty-free mascaras on here, I put it up on MakeupAlley, out of loyalty to my fellow Green Boarders. The list is in three parts: group 1, group 2, and group 3. This was also a good idea as felllow-MUAers gave useful feedback—for which my further (and now public) thanks and a shout-out to bellakahlua, combatwombat, kai1, and kitkat73—about Australian brands and queries about how I’d listed certain brands that I’d last checked a while back.

Quick handy rule of thumb: if you’re looking for cruelty-free beautification, and you’re either not too sure about a brand or haven’t time to check them out fully:
(1) ask on MUA,
(2) look for an Australian brand (cosmetics being TTBOMK cruelty-free there by law),
(3) look for a European brand that’s squeaky-green (ex. Lavera) and/or not global (so: only producing MU for the EU market, by EU rules, so finished products aren’t tested on animals and no new ingredients—newly developed since 2004—have been tested on animals). YMMV on bigger EU brands distributed further afield: if in doubt, write in and check…

There was a moment of worry in the case of Laura Mercier. I was a little concerned as I remember there being a cruelty-free statement on their site, in the customer service area (> FAQ); it’s now gone in the current site redesign. So I emailed them again…

When emailing companies asking about their cruelty-free status, I used to ask this question:

Are you cruelty-free?

Which is, with hindsight and knowing about manufacuturing and global-market developments in the last 10-15 years, not entirely sensible. Might even be a stupid question. See, it could perfectly easily ellicit this answer:


and maybe even the elaboration

we believe in being cruelty-free

and that could very well be true, but doesn’t necessarily mean

we do not test out products or ingredients on animals, nor do we pay others to do so on behalf, at any stage in production up to and including selling them

See, it all hinges on are you (and how you interpret the verb “to be”).

So I’m now asking this instead:

Dear [brand X],

I’ve very much liked your mascara, but had a couple of issues I’d be keen to see resolved before I consider repurchasing.

I would be very grateful if you could answer the following questions:

1. Are your products cruelty-free? That is: no animal testing by you, or by third parties on your behalf, on finished products and on ingredients?

2. What is your animal-testing status for markets requiring it (e.g., China)?

3. Where are your products made, their raw materials sourced, and what are the animal testing requirements there?

Many thanks in anticipation,

[yours truly]

Laura Mercier sent back an exemplary reply:

Laura Mercier is animal cruelty free. We do not test ingredients or products on animals, nor do we hire outside companies to do so for us. It is also stated on the back of our packaging that we do not test on animals. Also none of our products are manufactured in China, simply our packaging. Thank you for your interest in Laura Mercier and have a flawless day!

See what they did? A real human being actually read my email and answered my questions and did so in unequivocal terms. A fellow MUAer also emailed them and was similarly happy:

I am so pleased to see the bit of variation in the responses we received, while still conveying the same answer! I get so tired of the vagure & clearly automated ones.

Here at Laura Mercier we do not believe in testing our products or ingredients on animals. We have many women volunteers that try and test our new/existing products for us. We also do not hire outside/ 3RD party companies to do so either. Our products are not for sale in China. We also do not manufacture any products in China; simply the packaging. Thank you for your interest in Laura Mercier Cosmetics and have a flawless day!

They bothered to take the time and energy to read and reply properly. They’re also honest: to the point of firmness and a soupçon of feistiness, no shilly-shallying: it’s nice to see a company putting what they do and produce centre-stage, and standing up and fighting for them and their worth. It’s clear, straight-forward (lexis, syntax, semantics), and smacks of sincerity. This is a company that cares about their products, their reputation, and their customers.  Considerate, virtuous, and intelligent: showing some awareness that customers, products, and brand reputation fit together neatly in a relationship . That relationship can be (in simplistic terms) a vicious circle or a virtuous one. Here, it’s virtuous. Each item feeds the other two, and the result is happiness, satisfaction, trust, and loyalty: much of that stemming from LM’s loyalty, as demonstrated above, to their own products.

Laura Mercier gets a gold star for customer service that actually does what it says on the tin (and with courtesy, charm, graciousness, and good grace). I hope their lovely people had flawless days too! LM people in general: in particular, I should repeat my thanks to Ms Josie Rivera (Online Artist / Customer Service).

let’s be generous: not just a gold star, but a whole constellation of them, with dark-chocolate-coated champagne truffles underneath

Here’s an Italian company that has a solid past history on the non-testing front. Anecdotally, I can tell you I’ve used them years ago, found out about them while in Italy by word of mouth. But: they don’t blow their trumpet, nor do they posture around about what they believe and feel. Instead, the statement made on their site is a straight-up legal one, and honest about animal testing. Compare the two statements below:

PUPA Milan:

Are PUPA products tested on animals?

Pupa has always been committed to complying with present and future choices of the legislator.
Therefore, our finished products are not tested on animals, as prescribed by cosmetic regulations since 2004.
We therefore voluntarily commit to follow the guidelines of the European community which recommend, for ethical reasons, to consequentially carry out in vitro tests and in vivo tests on human volunteers, under dermatologic control.
The in vitro test as a matter of fact can predict possible irritative damage, so that each human volunteer can then safely undergo the in vivo testing.

As far as the ingredients are concerned, we need to make a distinction: those that have been used for decades to prepare cosmetics, come along with a toxicological file that includes data relevant to animal experimentation carried out in the past, while for raw materials of new generation, from 2009 on, it is mandatory to substitute animal experimentation with alternative, scientifically verified methods.

Furthermore, from 2009 to 2013, it will also progressively become illegal to sell cosmetics containing ingredients that were tested on animals in countries outside the EU.

In conclusion, notwithstanding the important steps forward that have been made in these last years, the exclusive use of alternative testing methods needs further commitment and development of scientific knowledge in order to guarantee all aspects of product and ingredient safety for customer protection, which remains the main priority.

Pupa and Pupa products have always been compliant with present and future choices of the legislator.

Emphasis above: in the original.

I should add, to clarify: “we voluntarily commit to follow the guidelines” isn’t shilly-shallying: right now these are guidelines, they don’t have legally-binding forcible status.

On which happy Italian note: this is the chocolate used in the truffles  pictured higher up; one of the best in the world, as per pro connoisseurs. It’s so sophisticated it comes with a “technical form for further instructions” (click image for link, PDF).

In the next examples, I’ve highlighted problematic portions in orange italic bold, and fluff that’s meant to make people feel more comfortable and make them think the company concerned is nice and loves fluffy bunny-rabbits, but has zero legal and/or actual factual status, in an appropriate magenta italic bold.

Estee Lauder group:

The Estée Lauder Companies Inc. is committed to the elimination of animal testing. We are equally committed to consumer health and safety, and bringing to market products that comply with applicable regulations in every country in which our products are sold. We do not conduct animal testing on our products or ingredients, nor ask others to test on our behalf, except when required by law. We evaluate our finished products in clinical tests on volunteer panels. Estée Lauder fully supports the development and global acceptance of non-animal testing alternatives. To this end, the Company works extensively with the industry at large and the global scientific community to research and fund these alternatives.

Note also: feel-good vocabulary: uses of “equal,” “evaluate” (with implications of value and valuing people, animals, etc.), “volunteer” (added assonance makes associative connection back to “value”), “alternatives” used twice.

Aveda (the greenest-looking part of EL Inc.):

Do you perform testing on animals?

No. All Aveda products are people-tested.

The Aveda Corporation is committed to the elimination of animal testing. We are equally committed to consumer health and safety, and bringing to market products that comply with applicable regulations in every country in which our products are sold.

We do not conduct animal testing on our products or ingredients, nor ask others to test on our behalf, except when required by law. We evaluate our finished products in clinical tests on volunteer panels.

The Aveda Corporation fully supports the development and global acceptance of non-animal testing alternatives. To this end, Aveda works extensively with the industry at large and the global scientific community to research and fund these alternatives.

To learn more, click here.

“Here” led to this (popup):

the end of animal testing

“In order to be beauty, it must also be good. Beauty is the result, but also the process.”
—dominique conseil, aveda president

Our stance on animal welfare is one of our founding principles: we don’t conduct animal testing, and don’t ask others to do it for us, unless the law requires it. We’re continually developing new products, but our safety testing relies on human volunteers and scientific databases.

where we stand

Aveda is working toward the end of animal testing—without exception. In 1989, we were the first privately held company to sign the Ceres Principles for corporate responsibility, which call for safeguarding of the Earth and “its inhabitants.” One of our most prized accolades is our 2004 PETA (People for the Ethical Treatment of Animals) Proggy Award for Progress: “Best Cruelty-Free Personal Care Products.”

The Estée Lauder Companies (which acquired Aveda in 1997) shares our commitment; it was one of the first cosmetic companies to completely abandon animal testing on finished products in the late 1980s, and its passion to find alternatives to animal testing continues.

The sad reality is that most ingredients have been tested on animals at some point, and new international regulations both support and challenge efforts to protect them. But we see an opportunity: along with advocacy groups and the global scientific community, we can work to develop more animal-free, in vitro (i.e. test tube) alternatives, to replace unnecessary in vivo tests (on living things).

where animals stand with us

Our commitment to being animal-friendly goes well beyond the confines of the lab; we live and breathe it. Just a few examples:

  • Our Blaine, Minnesota manufacturing plant is certified as a wildlife habit by the National Wildlife Federation, thanks to our restoration efforts.
  • We supported animal relief, donating to the Animal Humane Society, in the wake of Hurricane Katrina.
  • Over the past decade, our network has raised over $8 million for grassroots organizations that help protect endangered plants and animals.
  • In 2006, we sent more than 275,000 petitions—from our network and guests—to the United Nations and White House to support the Endangered Species Act.

Note overuse of “we” and continuous-action verbs. See how the use of “groups” and “community”, added onto the volunteers, helps to bring you into the “we?” Plus continuation of the huggy touchy-feely stuff, and appeals to feminine good nature.

That’s rhetoric. Language used to manipulate, sway, persuade. To appeal to feelings and everything else that’s not pure cold hard reason…

Those images down the side:

That bunny is the PETA one. Given that Aveda’s been taken off their lists, it should not be there any more. Even if the pink ears have gone green in this image… otherwise that’s going to be further ballast to the claim against EL of fraud (currently in court).

Aveda was bought by EL in 1997. In 2004, Aveda won the 1st annual Proggy (“progress”) Award from PETA; they went on to win another, the 6th annual one, in 2009. I’m sure having the weight of the EL marketeering fleet behind them can’t have hurt. Especially as the whole idea, from the animal rights point of view, was to show that you could be a successful big business and be cruelty-free. If, however, the products were being sold in China at that time, there’s going to be further potential for legal problems.

Dear Estee Lauder: Have a heart. A genuine real heart would be great; in the meantime, here’s a picture c/o The Twisted Chef of a gold-dusted salted caramel chocolate one from Clove Chocolatiers, Ottawa. Go Canadian gastroblogging go!


  1. Pingback: Laura Mercier Mineral Powder SPF 15 | Buying Cruelty-Free
  2. Kay

    This was a fantastically useful post – seriously. I am in the middle of writing to a bunch of make up companies for clearer statements on their brands, and I will certainly be adapting your “template”!!

    Also, thank you for posting the Laura Mercier info. I was super suspicious when their statement disappeared…

  3. Sophie

    I’m looking up information on Aveda as I’m hearing contradicting statements… Aveda Netherlands claims to be 100% cruelty free, worldwide. PETA (I have contacted them by email) claim they are also still 100% cruelty free and backed by PETA as well (they are back on PETA’s good list). However, Aveda’s statement still reads “we test when required by law” which is just ridiculous as they’re not in China so no law requires them to test on animals… I don’t trust them and I’m confused by PETA’s lack of action regarding this, how can they still back this company when they clearly state they test on animals? I’m going to continue boycott them…

    • gingerama

      Hi there,

      I completely agree: contradictory, and with a lot of claims that are untrustworthy (or indeed more rhetoric/PR than content). Slippery.

      THE QUICK LAZY ANSWER: keep emailing them, and post up all correspondence publicly! Anonymized, of course: removing/blacking out the names and contact information of the individuals who responded. I do this a lot, time/work and other commitments permitting; see for example “the art of asking questions about animal testing” (2012-09-15).


      Here’s my own position.

      1. I, too, like you, am choosing not to use or buy Aveda products right now. And indeed products by all companies in the Estee Lauder group. I am willing to reconsider and change my position, but only on provision of new positive data/information.

      For why, see these posts from back in February 2012, when the new first broke that there was a contradiction between Aveda’s de jure / claimed cruelty-free position and the de facto / practical situation, a.k.a. reality and truth:
      (a) a first post from when the news broke (2012-02-17)
      (b) update (1)
      (c) update (2): emails sent
      (d) update (3): comments

      2. I have little confidence in or respect for PETA. About as much as I do for the EWG: can sometimes be useful, may (sometimes) be well-intentioned, but those are the exceptions rather than the rule and There Are Problems. For more on why I am not a happy member of the PETA Cult, see:
      (a) these posts
      (b) ex. this recent one from 2013-04-06
      (c) and you remember when the news broke big time that EU law on animal testing in cosmetics was (finally!!!) changing? You wrote so well about it on your own blog, plus that excellent post you wrote on the Logical Harmony blog. I took the liberty of referring other readers to both of them c/o my own post on the matter here. Anyway: back to PETA: I was majorly irked by the coverage of these changes in EU law in North America, and the way PETA tried to make out like this was their big victory. Rather than that of the BUAV… and the fruits of their labours…
      (d) PETA’s lists are neither properly and fully researched (ex. they don’t even cover all brands in the USA, let alone the rest of the world: coverage for non-American brands is sketchy) nor kept up to date.

      3. On China: I’m aware that this is a changing situation, and that delicate negotiations are in progress. Also, that it’s not a black-and-white situation. The fact that a company has a presence on the Chinese market does not necessarily mean that their products are being tested on animals: see for example these posts.

      Sorry not to have a simple straight-forward answer to your questions: but, especially given how delicate the China situation is, anyone giving you a fast “yes/no” answer is being ignorant, or being foolish, or lying, or some combination of all three.

      One simple answer though: I respect a company who are honest and who treat their customers with honesty. Even if that means not telling their customers what they want to hear. See (in the last links) for example Weleda. But that’s a separate (albeit linked) ethical issue from the animal testing one…

      • Sophie

        Thank you so much for your additional insight!

        Interesting to see your older posts on Lavera and Weleda: I also researched this a couple of months ago and came to slightly different conclusions, but it still remains vague. I’ve gotten Weleda to admitt to not being 100% cruelty free (not just because of the 3 products years ago in China: turned out they sold their entire collection in China, including items that did undergo animal testing such as their shower gels. They have since removed all of those products (40+) from the Chinese Mainland market, yet have done this quietly – all a week after my article on it and other websites covering the article and putting pressure on Weleda). So although they made a mistake there, they did pull out of the Chinese market, at least the products that may have been tested on animals so I respect them for that, but it was a hassle to get them to change and admitt to anything, however after I went public with my findings they did take the Chinese webshop down…

        Lavera I don’t trust. A Chinese Google search shows Lavera stores in Chinese malls, next to their webshop featuring all their products. I confronted Lavera Europe with this, and they claim that this is not them, but an individual who imports these products illegally. Well… how can an individual set up official stores and a webshop offering their entire product line and not get fined and why is the website still up if it’s illegal? It doesn’t make any sense and all I get from Lavera is “well, it’s not us so we can’t do anything about it” which just baffles me. I have gone as far as getting NaTrue involved and they investigated it as well, however they came to the conclusion that “so far” no animal testing has been done in China on Lavera products. “So far” is not good enough for me, it means that any day these products may undergo animal testing.

        It can be really frustrating sometimes, especially when companies and pr agencies are against you (Weleda was not too happy with me during that time), but I just think it’s important for customers to know the truth. I will continue writing to Aveda and PETA and hopefully I will get a clear answer on all of this soon.

        Thank you for all the work you do! 🙂

        • gingerama

          Interesting! Keep me posted, and I’ll also do a couple of updates on here on your findings too.

          Alas, this is just a hobby blog and I work full-time, usually 50+ hours/week and often 70+, so I don’t have that much time for this blog’s research and writing… All the better to share, network, and refer readers around the place!

          Especially if we can compare notes on our interactions with companies, ex. here with Lavera and Weleda. In case we find that they’re sending out mixed messages, or contradictory or inconsistent ones (add to that incoherent, for very ignorant silly companies ex. the kind who don’t believe in sunscreen but try to convince people all sunscreen is toxic and skin cancer is a conspiracy-theory myth. I kid ye not.)

          That’s consumer strength: communication, sharing, and public dissemination of information. *Shakes fist*

  4. _GET["a"] Array ( [0] =>

    The actress said that she wanted all of her fans to know the truth and see that she is honest.
    Many women today are having cosmetic procedures, but not everyone will be emotionally
    prepared. You have a right to know what is going to go on during the procedure, therefore, ask whatever stuck your mind with your dermatologist.

    [Ed.–De-spammed, de-clawed, neutered: a whisper away from being relevant. Identifiers removed, especially the spammific “http://crcreativeservices […]” URL with embedded redirect at the end. Like the name, the way it includes a picture: that’s neat! *puerile chuckle*]

  5. Ildiko Tajti

    Could you help me please than which is really cruelty-free product from the above mentioned product? I am afraid a bit that i did not understand really proper these legal expressions… And do you have a trustable list of cruelty-free products what especially you made? Thanks in advance. 🙂 I really love your site, and try to translate it! 🙂 xoxo from Hungary!

    • gingerama

      Some comments in response.

      1. General comment and in response to “do you have a trustable list of cruelty-free products what especially you made?” [i.e. a *list* I made, not products]

      You are looking at a post and list that are TWO YEARS OUT OF DATE. You are in Hungary, in the European Union. The rules on cruelty-free cosmetic products changed NEARLY A YEAR AGO, making this post DOUBLY out of date.

      Information was correct at the time of posting, but just like in any other time-limited kind of writing (news, journals, magazines) the relevance / usefulness of a post can only be guaranteed for that time of writing. It is now only of historical interest.

      → Remedy: I would suggest reading the dates on blog posts. Maybe you’ve only just started reading blogs or being online at all? Well, those dates aren’t just for decoration: they are useful data too, and part of the information that you’re reading. Just like in newspapers!

      I would also suggest that “trustable” is precisely what one should not be doing. Trust no single individual or source of information. Don’t trust me! This isn’t about trust, after all: it’s about finding facts.

      → Solution: Be sceptical.

      Check everything. Check everything multiple times. Check with multiple sources. Check with primary sources, like the companies making products, and the law. Check with independent and critical sources, like advocay groups. Check even with information sources whose views you don’t like or disagree with: you are just looking for information, and looking for it in an impartial way.

      Trust no-one, question everything. After a while, and some more experience with doing your own research, I hope this gives you more confidence in yourself: then the next moe is from “trust no-one” to “trust my own brains, knowledge, good judgement, wisdom, research skills, reading and critical skills, and trained intuition.” 🙂

      2. “Which is really cruelty-free product?”

      → Read this post, or reread it attentively, and read other posts on here about what being cruelty-free means. And elsewhere. Many of them are linked to this post. I’m not going to read things for you: you need to do that for yourself, and do your own thinking, so as to understand. No-one can think and understand for you either: and what would be the point? You’re on the right track here, by asking “really”!

      As the famous quote goes, “own it.”

      3. “I do not understand really proper these legal expressions.”

      → Same response as for (2) above, and do your own research like in (1) above.

      It is important to understand what things mean: that is how one comes to understand the things themselves. Yes, that will mean reading various sorts of definition, description, and history. Yes, it will mean thinking, reasoning things through, and weighing up several ideas in your mind. That will take time and effort. But working to understand things, being geeky: that’s fun! And exercising your brain is good for it: keeping your brain in good shape is one of the best kinds of anti-ageing.

      Government and EU information is freely publicly avilable online: go look it up. EU information is available in every EU language, including Hungarian. I have linked all the current EU resources on the regulation of cruelty-free cosmetics elsewhere on this blog; you might also try using the SEARCH button.

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